SUMMARY

Systems Engineering and Laboratories seeks exemption from the requirements of 14 C.F.R §§ 61.23(a) 

and(c), 61.101(e)(4) and (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(a), 91.121,

91.151(b),91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) and (b), to operate an Unmanned Aircraft

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This

exemption will permit Systems Engineering and Laboratories to operate an UAS for the commercial 

purpose of conducting aerial video and photography of inspection sites over certain areas of the United

States.

INTRODUCTION OF THE PETITIONER

Systems Engineering and Laboratories provides its clients with information about how an incident

happened, surveys of incident sites, and reconstruction of incidents. The objective of Systems 

Engineering and Laboratories is to provide the best and most effective data to it’s clients.

BACKGROUND

Unmanned Aircraft Systems: 3DR Y6

Systems Engineering and Laboratories seeks an exemption to operate 3D Robotics systems for

compensation or hire within the NAS. The 3DR Y6 is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems in

tandem with its own dedicated remote system. The 3DR Y6 UAS is controlled by a Pixhawk

autopilot system, which is programmed using Mission Planner software. The 3DR Y6

has a maximum gross weight of 2 pounds 13 ounces with a diagonal size of 21.6 inches and a

maximum speed of approximately 48 knots. The 3DR Y6 is equipped with six main rotors driven by a

4000mAh LiPo 4S powered electric motors and a GoPro Hero 3 for image capture. The 3DR Y6 has 

been approved for use in other exemptions (Exemption No. 12646A)

The 3DR Y6 that will be operated by Systems Engineering and Laboratories will be registered in

accordance with 49 U.S.C. 44103, as well as 14 C.F.R. Part 47, and marked in accordance

with 14 C.F.R. Part 45.

BASIS FOR PETITION

Petitioner, Systems Engineering and Laboratories, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and FAA Modernization and Reform Act of 2012 (FMRA), Section

333, hereby petitions the Administrator to commercially operate the 3DR Y6

UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(a), 91.7(a), 91.119(a), 91.121,

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operation area associated with the unmanned 

aircraft and its operation, Systems Engineering and Laboratories’ operation of 3DR Y6 meets

the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and therefore,

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Systems Engineering and Laboratories requests relief from §§91.405(a),

91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate.
Systems Engineering and Laboratories submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Systems Engineering and Laboratories will use experienced personnel 

or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and 3DR Y6 Instruction Manual). Furthermore, Systems Engineering and 

Laboratories will document and maintain all maintenance records for the 3DR Y6 UAS.

Relief from certain requirements of § 61.23(a) & (c) entitled Medical certificates: Requirement 

and duration, is requested by Systems Engineering and Laboratories to operate the 3DR Y6

without an issued medical certificate. Systems Engineering and Laboratories will require all pilots to

have an annual physical to ensure the pilot is fit to command.

Relief from § 61.101(e)(4) & (5), 61.113(a), and 61.315(c)(2) & (3) entitled Recreational pilot

privileges and limitations, Private pilot privileges and limitations: Pilot in 

command, and What are the privileges and limits of my sport pilot certificate?

respectively, is requested by Systems Engineering and Laboratories to the extent necessary to allow

a PIC holding a recreational, private, or sport pilot certificate, as well as a state Driver’s license,

and who has demonstrated, by meeting minimum flight hour and currency requirements, that the

PIC is able to safely operate the 3DR Y6 UAS in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles, and structures where necessary.

Relief from § 91.7(a), entitled Civil aircraft airworthiness, because the 3DR Y6 UAS does not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Systems Engineering and Laboratories submits the they will ensure that the 3DR Y6 UAS is in an

airworthy condition, prior to every flight, by determining that the UAS is in compliance with the 

operating documents (i.e. Monthly Maintenance Log, and 3DR Y6 Professional Instruction Manual),

and that the aircraft are in a condition for safe flight.

Relief from § 91.119(c), entitled Minimum safe altitudes: General, because Systems 

Engineering and Laboratories intends to use the 3DR Y6 to collect aerial video and photographs of

buildings and structures involved in an investigation. Outside of structures involved in an investigation,

Systems Engineering and Laboratories will maintain safe distance from structures, people, vessels,

and vehicles.
Relief from § 91.121, entitled Altimeter Settings, as the 3DR Y6 UA will not have a typical 

barometric altimeter onboard. However, altitude information of the 3DR Y6 UA will be provided to the

PIC via GPS equipment and radio communications telemetry data link, which downlinks from the UA

to the Ground Control System for active monitoring of the flight path. This altitude information,

combined with Systems Engineering and Laboratories’ operation of the 3DR Y6 within visual line of 

sight at or below 400 feet AGL, will ensure a level of safety equivalent to § 91.121.

Relief from § 91.151(b), entitled Fuel requirements for flight in VFR condition. Systems 

Engineering and Laboratories submits that safety will not be affected by operation of the 3DR Y6 UA during

daylight visual meteorological conditions (VMC) under VFR, with enough battery power to fly for a total

duration of approximately 13 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 5 minutes

In accordance with 14 C.F.R. §11.81, Systems Engineering and Laboratories provides the following 

information in support of its petition for exemption:

A. Name and address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

Systems Engineering and Laboratories Corporation

Frank Johnson

12785 Hwy 64E

Tyler TX, 75707

903-566-1980 

fjohnson@sealcorp.com

B. The Specific §§ of 14 C.F.R. From Which Systems Engineering and Laboratories Seeks

 Exemption.

1. Systems Engineering and Laboratories Seeks Exemption From The Requirement Of

§

61.23(a) & (c).

§ 61.23, entitled Medical certificates: Requirement and duration, subsections (a) and (c) prescribe 

the following

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c)

of this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot certificate; 

(ii) When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires 

three or more pilots; or

(iii) When serving as a required pilot flightcrew member in an operation conducted under 

part 121 of this chapter if the pilot has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:
(i) Second-in-command privileges of an airline transport pilot certificate in part 121 of this chapter

(other than operations specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate—

(i) When exercising the privileges of a private pilot certificate;

(ii) When exercising the privileges of a recreational pilot certificate; 

(iii) When exercising the privileges of a student pilot certificate;

(iv) When exercising the privileges of a flight instructor certificate and acting as the pilot in 

command;

(v) When exercising the privileges of a flight instructor certificate and serving as a 

required pilot flight crewmember;

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, 

commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or 

(vii) When performing the duties as an Examiner in an aircraft when administering a 

practical test or proficiency check for an airman certificate, rating, or authorization.

(c) Operations requiring either a medical certificate or U.S. driver's license

(1) A person must hold and possess either a medical certificate issued under part 67 of this 

chapter or a U.S. driver's license when—

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in

a light-sport aircraft other than a glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a 

glider or balloon;

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while 

acting as pilot in command or serving as a required flight crewmember of a light-sport 

aircraft other than a glider or balloon; or

(iv) Serving as an Examiner and administering a practical test for the issuance of a sport 

pilot certificate in a light-sport aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this paragraph must— (i)

Comply with each restriction and limitation imposed by that person's U.S. driver's 

license and any judicial or administrative order applying to the operation of a motor 

vehicle;

(ii) Have been found eligible for the issuance of at least a third-class airman medical 

certificate at the time of his or her most recent application (if the person has applied for a 

medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person has 

held a medical certificate) suspended or revoked or most recent Authorization for a 

Special Issuance of a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make that 

person unable to operate a light-sport aircraft in a safe manner.

2. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §61.101(e)(4) & (5).

§ 61.101, entitled Recreational pilot privileges and limitations, subsection (e)(4) states the 

following:
(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as

pilot in command of an aircraft—

(4) For compensation or hire;

(5) In furtherance of a business;

3. Systems Engineering and Laboratories Seeks Exemption From The Requirement Of

§ (5),61.113(a).

§ 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsection (a) states 

the following:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft.

4. Systems Engineering and Laboratories Seeks Exemption From The Requirement Of

§61.315(c)(2) & (3).

§ 61.315, entitled What are the privileges and limit of my sport pilot certificate?, subsection (c)(2) & 

(3) states the following:

(c) You may not act as pilot in command of a light-sport aircraft: 

(2) For compensation or hire.

(3) In furtherance of a business.

5. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.7(a).

§ 91.7, entitled Civil aircraft worthiness, subsection (a), states that:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

6. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.119(c).

§ 91.119, entitled Minimum safe altitudes: General, subsection (c) states that:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

7. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.121.

§ 91.121, entitled Altimeter Settings, subsection (a)(1) states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;
(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

8. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of § 91.151(b).

§ 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 20 minutes.

9. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.405(a).

§ 91.405, entitled Maintenance required, subsection (a) states: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter.

10. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.407(a)(1).

§ 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration,

subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance,

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter.

11. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.409(a).

§ 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

12. Systems Engineering and Laboratories Seeks Exemption From The Requirement

Of §91.417(a) & (b).

§ 91.417, entitled Maintenance records, subsections (a) & (b), state the following:
(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or

operator shall keep the following records for the periods specified in paragraph (b) of this 

section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an 

aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii)

The current status of life limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to 

be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required

by the inspection program under which the aircraft and its appliances are maintained

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to 

the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to 

service.

C. The Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason

Systems Engineering and Laboratories Seeks The Relief.

1. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason

Systems Engineering and Laboratories Seeks Relief From § 61.23(a) & (c).

Relief from § 61.23(a), entitled Medical certificates: Requirement and duration, is requested to the 

extent necessary to allow a PIC, with a current physical from a physician, but no medical

certificate, to pilot the 3DR Y6.

The limitations of § 61.23(a) sets forth the level of medical certificate one needs in order to pilot an 

aircraft. However, because the 3DR Y6 does not require a physical pilot inside the vessel and
because the 3DR Y6 can be programmed to safely return, within the same limitations the PIC would

be required to follow, to the GCS and land in the event of loss of range or other emergencies a current

physical will maintain a similar level of safety as the medical certificate would. Systems Engineering

and Laboratories requests that a current physical and valid driver’s license meet the safety

requirements of this section.

2. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason

Systems Engineering and Laboratories Seeks Relief From § 61.101(e)(4) & (5),

61.113(a), And

61.315(a).

Relief from §§ 61.101(e)(4) & (5), 61.113(a), and 61.315(a), entitled Recreational pilot privileges and 

limitations, Private pilot privileges and limitations: Pilot in command, and What are the privileges 

and limits of my sport pilot certificate?, is requested to the extent necessary to allow a PIC holding a

recreational, private, or sport pilot certificate, as well as valid driver’s license and current physical,

and who has met certain flight hour and currency requirements, to conduct the proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth state that private, recreation, or sport pilots may, 

for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire.

As set forth more fully below, Systems Engineering and Laboratories submits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the 3DR Y6 UAS unless that

PIC has met certain flight hour and currency requirements, demonstrating that the PIC is ableto safely

operate either the 3DR Y6 in a manner consistent with the operations specifications as described in

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles, and structures that are not part of an investigation

Further, Systems Engineering and Laboratories submits that all flights of the 3DR Y6 conducted by the

PIC pursuant to the grant of this Petition: (1) will be incidental to Forensic Analysis

& Engineering’s business; and (2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason

System Engineering and Laboratories Seeks Relief From § 91.7(a).

Relief from § 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Forensic 

Analysis & Engineering to determine that the 3DR Y6 UAS is in airworthy condition prior to every flight by

ensuring that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and 3DR Y6

Instruction Manual).

Systems Engineering and Laboratories seeks the requested relief because the 3DR Y6 UAS does not

require an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H. Therefore,

Systems Engineering and Laboratories will ensure that the 3DR Y6 UAS is in airworthy condition 

based upon compliance with the operation documents (i.e. Monthly Maintenance Log, and

3DR Y6 Instruction Manual) prior to every flight, and further, determine that the aircraft is in

condition for safe flight, as stated in the conditions and limitations below.
4. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason

System Engineering and Laboratories Seeks Relief From § 91.119(c).

Relief from § 91.119(c), entitled Minimum safe altitudes: General, will be necessary in order to conduct 

various investigations. The 3DR Y6 would need to get close to vessels, vehicles, and structures

involved in the investigation in order to capture clear photographs of the inspection site.

Specifically, the § limits getting within 500 feet of any person, vessel, vehicle, or structure. Systems 

Engineering and Laboratories requests relief from this limit against vessels, vehicles, and structures only 

when part of an active investigation with the property owner’s previous permission. Considering the hovering

capabilities of the 3DR Y6, which is ± 0.1 m vertically (when Vision Positioning is activated) and ± 1.5 m

horizontally, a safer than 500 feet distance can be maintained Furthermore, Systems Engineering and 

Laboratories will incorporate a second remote system so that the visual observer or a third participant can 

operate the photography while the PIC can verify that 3DR Y6 is maintaining a safe distance from the 

structure, vehicle, or vessel.

5. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason Systems Engineering 

and Laboratories Seeks Relief From § 91.121.

Relief from § 91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DR Y6 

UAS, which utilize barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the 

FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) 

in feet above ground level (AGL), Systems Engineering and Laboratories seeks the requested relief because 

the 3DR Y6 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief is sought to the extent necessary to comply 

with the applicable conditions and limitations stated below, As more fully set forth herein, an equivalent level 

of safety will be maintained since the 3DR Y6 UA is equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides that PIC with altitude information of the UA on the heads up display of the GCS.

6. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason Systems Engineering 

and Laboratories Seeks Relief From § 91.151(b).
Relief from section 91.151(b), entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered 3DR Y6 UA during daylight hours in visual 

meteorological conditions, under visual flight rules, for a total duration of 13 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Systems 

Engineering and Laboratories seeks the requested relief because without an exemption from this rule will 

severely constrain the practicality of any aerial video or still photo flight operations that Systems Engineering 

and Laboratories proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR Y6 UAS the operation documents, 

and Systems Engineering and Laboratories’ proposed operating limitations, ensure that Systems 

Engineering and Laboratories will safely operate the battery powered 3DR Y6 UA during daylight hours in 

visual meteorological conditions, under visual flight rules, with enough battery power to fly for a total duration 

of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 5 minutes.

7. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason Systems Engineering 

and Laboratories Seeks Relief From §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), And 91.417(a) & (b).

Since §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), And 91.417(a) & (b) only apply to aircraft with 

an airworthiness certificate, Systems Engineering and Laboratories requests relief from these §§ 

because the 3DR Y6 UAS does not require an airworthiness certificate. As set forth more fully below,

the 3DR Y6 UAS meets the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section

333 for operation without an airworthiness certificate. Accordingly, Systems Engineering and 

Laboratories will use trained technicians to perform maintenance, alterations, or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS

operating documents (i.e. Monthly Maintenance Log and 3DR Y6 Instruction Manual). Furthermore,

Systems Engineering and Laboratories will document and maintain all maintenance records for the

3DR Y6 UAS.

D. The Reason Why Granting Systems Engineering and Laboratories Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Systems Engineering and 

Laboratories to safely, efficiently, and economically perform aerial video and photography of homes, 

vehicles, vessels, construction sites, and other incident sites over certain areas of the United States.

Additionally, use of the 3DR Y6 UAS will decrease congestion of the NAS, reduce pollution, and provide

significant benefits to the economy. Notably, the benefits Systems Engineering and Laboratories

proposed operation of the 3DR Y6 UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3DR Y6 UA is battery powered and serve as a safe, efficient, and economical alternative to the

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned
aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR Y6 UAS would

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as

increase the safety of life and property in the air and on the ground.

Additionally, when Systems Engineering and Laboratories must collect video and photographic evidence

of ships and vessels off the coast, using the 3DR Y6 will result in a reduction of congestion in the

waterways and ultimately a reduction in fuel costs.

Furthermore, by reducing the number of manned aircraft operations in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The 3DR Y6 UA does not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video 

and photography missions would result in fewer aircraft that must be handled by air traffic

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3DR Y6 UAS.

Conducting aerial image acquisitions with the 3DR Y6 UAS, instead of manned aircraft, will greatly benefit

the public by drastically reducing the levels of air and noise pollution generated during traditional

aerial video and still photography flight operations. By using battery powered and electric motors, the

3DR Y6 UAS produce no air pollution, and is the most viable environmentally conscious

alternative to the cabin class, four or six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 10-15 gallons per hour

of leaded aviation fuel. The 3DR Y6 UA, while reducing the carbon footprint of aerial acquisitions,

also eliminates noise pollution, as the UA is propelled by battery powered electric motors, rather than

an internal combustion engine.

By using the 3DR Y6 UAS to perform aerial image acquisitions, the substantial risk to life and property in

the air and on the ground, which is usually associated with traditional manned aircraft flight

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew

members located onboard the aircraft, the 3DR Y6 UA (weight approximately 2 pounds 13 ounces at

its maximum gross weight with length a 23.3 inches diagonal, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air, compared to

the manned aircraft that typically conduct similar operations (weight approximately 3000 pounds with

a wingspan of approximately 32 feet, a length of 34 feet, and a fuel capacity of 80 gallons).

3. Performing Aerial Video and Photography Operations With The 3DR Y6 UAS Will 

Benefit The Economy.

In addition to being safe and efficient, the 3DR Y6 UAS is also an economical alternative to using

manned aircraft to conduct similar aerial operations. As such, operation of the 3DR Y6 UAS will

allow United States based companies, like Systems Engineering and Laboratories, to remain

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of

aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in

order to remain competitive. Operating the battery 3DR Y6 UAS is one such technology that not 

only allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.
By operating the 3DR Y6 UAS companies, such as Systems Engineering and Laboratories, can

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial

performance of U.S. companies, through commercial use of the 3DR Y6 UAS, provides a stable

workforce that increases consumer spending; improves local, state, and federal tax revenues and

allows companies to invest in research and development in order to remain competitive both in the

United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Systems Engineering and Laboratories’ proposed operations of the 3DR Y6 UAS will not implicate any

privacy issues. Specifically the 3DR Y6 UAS will be operated in compliance with operating 

documents (i.e. Monthly Maintenance Log, and 3DR Y6 Instruction Manual) additionally requiring

property owner involvement as well as local law enforcement notification, and in accordance with the

Federal Aviation Regulations)

E. The Reason Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety Equal To That Provided By The Rule From 

Which Systems Engineering and Laboratories Seeks Exemption.

1. Reasons Why the 3DR Y6 UA Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, Systems Engineering and Laboratories’ operation of the 3DR Y6 UAS

meets the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333, and will

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FAA Modernization and Reform Act of

2012 (FMRA) Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 
and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system.

In seeking this exemption, Systems Engineering and Laboratories submits that the 3DR Y6 UAS can

operate safely in the NAS pursuant to FAA Modernization and Reform Act of 2012 (FMRA) Section

333, as demonstrated by: (a) the characteristics of the 3DR Y6 UA; (b) the pilot certification

requirement; and (c) the specific operating limitations.

a. The Specifications Of The 3DR Y6 UAS Demonstrate Its

Safe CharacteristicsThe 3DR Y6 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to the national security considering its size, weight, speed, and operational 

capability.

i. Technical Specifications Of The 3DR Y6 UAS.

The technical specifications of the 3DR Y6 UAS are set forth by the 3DR Y6 Build Manual-vA herein 

attached as Appendix A. The 3DR Y6 UAS is controlled by a Pixhawk autopilot system, which is 

programmed using Mission Planner software. 

ii. The 3DR Y6 UAS Autonomous Flight And Navigation Mode

Enable The UAS to Remain Within A Defined Operational Area.

The 3DR Y6 UAS may be operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the 3DR Y6 UAS is provided in the Mission 

Planner user manual, found at http://planner.ardupilot.com/wiki/mission-planner-overview, and 

Pixhawk Manual Rev 7 herein attached as Appendix B

iii. The 3DR Y6 UAS Is Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the 3DR Y6 UAS will continue its programmed flight plan or Return to Land 

(RTL), depending on user settings and flight mode. At the end of the mission or at the end of the RTL 

process, the craft will descend to the takeoff position, shut down, and disarm the motors. 

Additional failsafe features include geofencing, battery alarms, and automated 

triggering of RTL or auto land in case of low GPS signals or loss of controller or ground 

station communication. 
A complete description of the Failsafe Functions of the 3DR Y6 are set forth at 

http://planner.ardupilot.com/wiki/mission-planner-overview 

iv. The 3DR Y6 GCS And Its Operation.

A complete description of the operation and specifications of the 3DR Y6 GCS and flight control software

is provided at http://planner.ardupilot.com/wiki/mission-planner-overview

b. Flight Operations Of 3DR Y6 UAS Is Limited To The

Line Of Sight Of A Certified Pilot in Command With A Safety 

Observer(SO).

Systems Engineering and Laboratories will be the only company to authorize PICs for the 3DR Y6.

Additionally, a safety observer and photographer will assist the PIC during flight time.

c. Flights Of 3DR Y6 UAS Will Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, Systems Engineering and Laboratories proposes to commercially

operate 3DR Y6 UAS for the special purpose of conducting aerial video and photography 

over certain areas of the United States, pursuant to the following specific operating

limitations1. Operations authorized by this grant of exemption will be limited to the

following aircraft described in the operating documents, rotorcraft UASs weight less 

than 55 pounds maximum gross weight: 3DR Y6 Unmanned Aircraft System. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial surveying, video, and photography.

3. The UA may not be flown at an indicated airspeed exceeding 50 knots.

4. The UA must be operated at an altitude of no more than 400 feet AGL, as indicated by the 

procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UA must be operated within VLOS of the PIC at all times. This requires the PIC to be 

able to use human vision unaided by any device other than corrective lenses, as specified on 

the PIC’s State issued Driver’s License

6. The use of the first person view by the PIC or SO is not permitted.

7. All operations must utilize an SO. The SO may be used to satisfy the VLOS requirement as 

long as the P IC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or 

her designation for the duration of the flight. The PIC must ensure that the SO can perform 

the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to

operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 
procedures outlined in the operating documents, the conditions and limitations contained in 

the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator's responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for extension or

amendment to the grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. The GCS must be included in the 

preflight inspection. All maintenance and alterations must be properly document in the 

aircraft records.

11. Any UAs that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.ge replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry in 

the aircraft records12. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment, not already covered in

the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacture Safety

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

17. The PIC must possess a private, sport, recreational, or higher pilot certificate, at least a 

current Driver’s License, and a current physical from an approved practitioner.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles, and structures not involved in an investigation. PIC qualification flight hours must be

logged in a manner consistent with 14 C.F.R. § 61.51(b) Flights for the purposes of 

training the operator’s PIC are permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under VMC. If flight at night is required, a special request will 

be made at the FAA office closet to proposed area of operations. Flights under SVFR are 

not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on 

current FAA published aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management must be

made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended point and 

land the UA with 25% battery power remaining.

25. The operator must obtain an ATO issued Certificate of Waiver or Authorization (COA)

prior to conducting any operations under the grant of exemption. This COA will also require

theoperator to request a NOTAM not more than 72 hours in advance, but not less than 48 

hours prior to operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) 

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be made as 

large as practical

27. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA must comply with the FCC or other appropriate government oversight agency 

requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the 

PIC at the GCS of the UAS any time the UAS in operating. These documents must be 

made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and 

activities at the time.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, 

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If situation arises 

where nonparticipating persons leave such protection and are within 500 feet of the U,

flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles, or structures where the 

owner/controller of such vessels, vehicles, or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, So, operator trainees, or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be 

conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of

the operational area as defined by the applicable COA must be reported to the FAA’s UAS

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the NTSB per

instructions contained on the NTSB website: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of § 61.23(a) Would Not

Adversely Affect Safety.

Systems Engineering and Laboratories submits that the equivalent level of safety established by § 61.23(a) 

will be maintained because no PIC will be allowed to operate the 3DR Y6 unless that PIC has a current

physical on file with Systems Engineering and Laboratories and a valid Driver’s License

The FAA has previously granted relief from § 61.23(a) & (c) specific to UAS, in circumstances similar, in 

all material respects to those presented herein (e.g. Exemption Nos. 11410, 11553, 11257, 11213,

11437, 11150A).

3. Reasons Why An Exemption From The Requirements Of §§ 61.101(e)(4) & (5),

61.113(a), And 61.315(a) Would Not Adversely Affect Safety.

Systems Engineering and Laboratories submits that the equivalent level of safety established by §§

61.101(e)(4) & (5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to 

operate the 3DR Y6 unless that PIC has demonstrated, by meeting minimum flight-hour and

currency requirements, that the PIC is able to safely operate the 3DR Y6 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles, and structures.

Considering Systems Engineering and Laboratories’ proposed area of operations, and the operating 

limitations set forth above; the parallel nature of private, recreational, or sport pilot aeronautical 

knowledge requirements to those of commercial pilot requirements; and the airmanship skills 

necessary to safely operate the 3DR Y6 UAS, Systems Engineering and Laboratories submits that

the additional manned airmanship skills unnecessary for Systems Engineering and Laboratories’

specific proposed flight operations.

Systems Engineering and Laboratories will not allow any PIC to operate the 3DR Y6 UAS unless that 

PIC has demonstrated, by meeting minimum flight hour requirements or the 3DR Y6 UAS

training and currency requirements, that the PIC is able to safely operate the 3DR Y6 UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles, and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours 

as a UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings 

in the preceding 90 days (for currency purposes).

Accordingly, Systems Engineering and Laboratories will ensure safe operations by not allowing any PIC

to operate the 3DR Y6 Professional UAS unless that PIC has demonstrated, by meeting 

minimum flight hour and currency requirements, that the PIC is able to safely operate the 3DR 

Y6 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles, and structures.

The FAA has previously granted relief from § 61.113(a) & (b) specific to UAS, in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos, 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158,

11159, 11160, 11161.)

4. Reasons Why An Exemption From The Requirements Of § 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by § 91.7(a) will be maintained because prior to every flight, 

Systems Engineering and Laboratories will ensure that the 3DR Y6 UAS is in an airworthy condition

based upon the UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein.

Additionally, the FAA has previously granted relief from § 91.7(a) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 1116, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of § 91.119(c) Would Not

Adversely Affect Safety.

The equivalent level of safety established by § 91.119(c) will be maintained because 3DR Y6 will not be

flown closer to any Vessel, Structure, or Vehicle without prior authorization from the owner.

Additionally, the 3DR Y6 has automated hover capabilities which allow the 3DR Y6 to maintain

position within ± 0.2m vertically and ± 1.5m horizontally.

The FAA has previously granted relief from § 91.119(c) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11111, 11112, 11136, 11188, 11208, 11213, 11437, 11508, 11671)

6. Reasons Why An Exemption From The Requirements Of § 91.121 Would Not

Adversely Affect Safety.
The equivalent level of safety established by § 91.121 will be maintained because the altitude 

information of the 3DR Y6 UA will be provided to the PIC via GPS equipment and a radio

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of

the flight path and altitude. This altitude information, combined with Systems Engineering and 

Laboratories’ operation of the 3DR Y6 UA within visual line of sight, at or below 400 feet AGL, will

ensure a level of safety equivalent to § 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is

automatically established by the UAS at ground level.

The FAA has previously granted relief from § 91.121 specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 11161).

7. Reasons Why An Exemption From The Requirements Of § 91.151(b) Would Not

Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety

established by § 91.151(b) as a result (1) the technical specifications of the 3DR Y6 UAS; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight operations.

Accordingly, Systems Engineering and Laboratories will ensure that it will safely operate the

battery powered 3DR Y6 UA during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes..

The technical specifications of the 3DR Y6 UAS; the limitations on the proposed flight operations;

and the location of the proposed operations, will ensure an equivalent level of safety established by

§ 91.151(b). Furthermore, safety will be ensured as the 3DR Y6 UAS provide audible and visual 

warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning

occurring at approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery power, the 3DR Y6 UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning § 91.151 establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums 

prescribed in § 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 

previously granted relief from § 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 1158, 11159, 11160, 11161).

8. Reasons Why An Exemption From The Requirements Of §§ 91.405(a), 91.407(a)(1),

91.409(a), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Systems Engineering and Laboratories submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requirements established by §§

91.405(a),
91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) will be met because Systems Engineering 

and Laboratories will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the operating 

documents (i.e. Monthly Maintenance Log and 3DR Y6 Instruction Manual). Furthermore, Systems 

Engineering and Laboratories will document and maintain all maintenance records for the 3DR Y6

UAS.

Since the 3DR Y6 UAS will be inspected as prescribed by the operating documents, Systems Engineering 

and Laboratories will maintain the equivalent level of safety established by §§91.405(a),

91.409(a)(1) & (2). A copy of the 3DR Y6 User Manual is attached hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because Systems Engineering and 

Laboratories will use trained technicians to perform maintenance, alterations, or preventive maintenance

on the UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by

§§91.407(a) and 91.407(b), because maintenance of the 3DR Y6 UAS will be performed by trained

technicians. Maintenance will be documented and maintained utilizing the Monthly Maintenance Log.

Significantly, previous exemptions granted by the FAA concerning §§ 91.405(a), 91.407(a)(1),

91.409(a)(1) & (2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered.

In consideration of Systems Engineering and Laboratories’ proposed operating limitations, the

operating documents, and the technical aspects of the 3DR Y6 UAS, Systems Engineering and 

Laboratories submits that safety will not be adversely affected by granting exemption from §§

91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 1106, 11067, 11080, 11109, 11110, 11112,

1113, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

9. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14

C.F.R. § 21.16 entitled Special Conditions, Systems Engineering and Laboratories requests that the

FAA prescribe special conditions for the intended operation of the 3DR Y6 UAS, which contain

such safety standards that the Administrator finds necessary to establish a level of safety equivalent

to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a), & (c), 61.101(e)(4) &

(5), 61.113(a) & (b), 61.315(c)(2) & (3), 91.7 (a), 91.119(c), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). Such special conditions will permit 

safe operation of the UA for the limited purpose of conducting aerial video and photography over 

certain areas of the United States for compensation or hire. FAA Modernization and Reform Act of

2012 (FMRA) Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the 3DR Y6 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain

adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. §

21.16, entitled Special Conditions, stated the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of novel or unusual design feature of the aircraft, aircraft engine, or propeller, he 

prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine, or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

Therefore, in accordance with FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and 14

C.F.R. § 21.16, the FAA may prescribe special conditions for Systems Engineering and 

Laboratories intended operation of the 3DR Y6 UAS, which contains such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a),

61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a),

91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From

Which Systems Engineering and Laboratories Seeks Exemption.

Systems Engineering and Laboratories seeks exemption from the requirements of 14 C.F.R. §§ 61.23(a) &

(c),

61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a), 91.417(a) & (b).

G. A Brief Description Of The Nature Of The Exemption Systems Engineering and 

Laboratories Seeks.

This exemption will permit Systems Engineering and Laboratories to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography

over certain areas of the United States for forensic inspections.

H. Any Additional Information, Views, Or Arguments Available To Support Systems 

Engineering and Laboratories Request.

This petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the 

NS. As such, Systems Engineering and Laboratories’ request for exemption may be granted pursuant

to the authority of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 and 14 C.F.R. Part

11, as set forth above.

The FAA Modernization and Reform Act of 2012 (FMRA) Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a
threat to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification.

As discussed in detail above, Systems Engineering and Laboratories will operate the 3DR Y6

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose

a threat to national security.

CONCLUSION

As set forth herein, Systems Engineering and Laboratories seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit

safe operation of the 3DR Y6 UAS commercially, without an airworthiness certificate, for the limited

purpose of conducting aerial video and photography over certain areas of the United States. By

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012 (FMRA), while also advancing the interests of the public, by

allowing Systems Engineering and Laboratories to safely, efficiently, and economically operate the

3DR Y6 UAS commercially within the NAS

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, Systems Engineering and Laboratories respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. §§ 61.23(a)

& (c) , 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 

91.151(b),91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b), and permit Systems Engineering and 

Laboratories to operate the 3DR Y6 UAS commercially for the purpose of conducting aerial video

and photography over certain areas of the United States for forensic inspections.

Dated December 9, 2015

Respectfully submitted,

Frank Johnson

Systems Engineering and Laboratories

12785 State Hwy 64 E

Tyler TX, 75707

903-566-1980